CPA-Zicklin Index

The CPA-Zicklin Index benchmarks the political disclosure and accountability policies and practices of leading U.S. public companies. Issued annually, it is produced by the Center for Political Accountability in conjunction with the Zicklin Center for Business Ethics Research at The Wharton School at the University of Pennsylvania.

How to Get a Perfect Score on the CPA-Zicklin Index

The CPA-Zicklin Index assesses companies’ political spending disclosure practices and political spending policies. The ideal political spending policy explains:

The company’s process for making contributions or expenditures to influence political and/or judicial campaigns;

How management and the board oversee such decisions; and

The public policy considerations that influence such decisions.

The CPA-Zicklin Index uses 24 metrics, or “indicators,” to assess companies’ policies and disclosure practices. Below, please find a sample disclosure report as well as model policy language from some of the top-scoring companies on the Index. (For more guidance on how the Index is scored, please see theIndex Scoring Guidelines.)

#1 Does the company publicly disclose corporate contributions to political candidates, parties and committees, including recipient names and amounts given?

#2 Does the company publicly disclose payments to 527 groups, such as governors associations and super PACs, including recipient names and amounts given?

#3 Does the company publicly disclose independent political expenditures made in direct support of or opposition to a campaign, including recipient names and amounts given?

#4 Does the company publicly disclose payments to trade associations that the recipient organization may use for political purposes?

#5 Does the company publicly disclose payments to other tax-exempt organizations, such as 501(c)(4)s, that the recipient may use for political purposes?

#6 Does the company publicly disclose a list of the amounts and recipients of payments made by trade associations or other tax exempt organizations of which the company is either a member or donor?

#7 Does the company publicly disclose payments made to influence the outcome of ballot measures, including recipient names and amounts given?

#8 Does the company publicly disclose the company’s senior managers (by position/title of the individuals involved) who have final authority over the company’s political spending decisions?

AFLAC Inc.: "Corporate contributions made by Aflac are reviewed by outside legal counsel for compliance with applicable campaign finance and related laws, and reviewed and approved by an Aflac Senior Vice President reporting directly to Aflac's General Counsel for consistency with Aflac's contribution policy and criteria."

#9 Does the company publicly disclose an archive of each political expenditure report, including all direct and/or indirect contributions, for each year since the company began disclosing the information (or at least for the past five years)?

To receive full credit, past political spending reports must be maintained on the website for five years. A partial archive results in partial credit. (Companies that are in their first year of voluntary disclosure aren’t penalized for not maintaining an archive.)

#10 Does the company disclose a detailed policy governing its political expenditures from corporate funds?

To receive full credit, the company’s policy must address the kinds of political contributions permitted using corporate funds as well as management and board oversight of such spending.

#11 Does the company have a publicly available policy permitting political contributions only through voluntary employee-funded PAC contributions?

This indicator does not have a point value and is used for research purposes only.

#12 Does the company have a publicly available policy stating that all of its contributions will promote the interests of the company and will be made without regard for the private political preferencesof executives?

Freeport-McMoRan Inc.:"FCX's political spending reflects our interests as a company and not those of any individual director, officer or employee."

#13 Does the company publicly describe the types of entities considered to be proper recipients of the company’s political spending?

Boeing Co.: "Since 2010, the Company has not made any contributions from corporate funds to state or local candidates or political parties. Also, Boeing has not expended any corporate funds since 2011 in support of or opposition to ballot initiatives, or since 2012 for political contributions to section 527 entities. Boeing also has not contributed and does not contribute corporate funds to Super PACs, or for electioneering communications or independent expenditures. Corporate contributions to federal candidates are prohibited by federal law, and Boeing accordingly makes no such contributions."

#14 Does the company publicly describe its public policy positions that become the basis for its spending decisions with corporate funds?

Southwestern Energy Co.: "Political contributions are to be made in accordance with the Company’s political contributions policy only as permitted under federal, state and local laws to help elect candidates who demonstrate integrity and character, support the domestic production of oil and natural gas and understand the contribution of the oil and natural gas industry to our national economy and national security. Other factors considered in determining whether to support a candidate include: Whether the candidate sits on a committee that addresses legislation affecting our businesses; Whether the candidate represents a district or state in which Southwestern Energy presently conducts or intends to conduct significant operations; The committee standing and ranking of the candidate; The candidate’s elected leadership position; and The candidate’s voting record."

#15 Does the company have a public policy requiring senior managers to oversee and have final authority over all of the company’s political spending?

United Continental Holdings Inc.: "You may not make political contributions on behalf of United, including, but not limited to, monetary or in-kind contributions, the use of corporate resources, email, personnel or facilities, without obtaining prior approval from Legal and Government Affairs."

#16 Does the company have a publicly available policy that the board of directors regularly oversees the company’s corporate political activity?

BB&T Corp.: "The Nominating and Corporate Governance Committee of the Board annually reviews this Statement of Political Activity and receives reports that provide information on BB&T’s contributions to trade associations, PACs and related lobbying activity."

#17 Does the company have a specified board committee that reviews the company’s policy on political expenditures?

Coca-Cola Co.: “The Committee shall review the Company's public policy advocacy efforts, including all political contributions, to ensure alignment with Company policy and our overall values. This review will occur at least annually. In addition, the Committee will periodically review the Government Advocacy and Political Contributions policy to ensure its efficacy.”

#18 Does the company have a specified board committee that reviews the company’s political expenditures made with corporate funds?

Costco Wholesale Corp.: "The Nominating and Governance Committee of the Board of Directors, which is comprised exclusively of independent directors, reviews the Company’s spending on politics and advocacy..."

#19 Does the company have a specified board committee that reviews the company’s payments to trade associations and other tax-exempt organizations that may be used for political purposes?

United Parcel Service Inc.: "UPS will request trade associations that received from UPS total payments of $50,000 or more in a given year to report the portion of UPS dues or payments used for expenditures or contributions that if made directly by UPS would not be deductible under Section 162(e)(1)(B) of the Internal Revenue Code. The Company will disclose such information received from such trade associations semi-annually on the UPS website. Prior to publication, the report shall be presented to the Nominating and Corporate Governance Committee of the UPS Board of Directors."

#20 Does the company have a specified board committee that approves political expenditures from corporate funds?

ConocoPhillips: "The Public Policy Committee has authorized a strict process for the justification, approval and reporting of any corporate political contributions made in states that permit corporate contributions. The Public Policy Committee also sets a bi-annual budget for such corporate contributions in the U.S. and Canada."

#21 Does the company have a specified board committee, composed entirely of outside directors, that oversees its political activity?

McKesson Corp.: "The Committee shall consist of three or more directors each of whom has been determined, in the business judgment of the Board, to qualify as an independent director (“Independent Director”) under (a) the rules of the New York Stock Exchange (the “NYSE Rules”), (b) the Company’s Corporate Governance Guidelines, and (c) the categorical standards adopted by the Board in accordance with such Guidelines to assist in determining director independence (the “Categorical Standards”). The Board is responsible for the appointment and removal of Committee members."

#22 Does the company post on its website a detailed report of its political spending with corporate funds semiannually?

To receive full credit, a company must post its political spending reports semiannually. (Annual reporting warrants half credit.)

#23 Does the company make available a dedicated political disclosure web page found through search or accessible within three mouse-clicks from homepage?

To receive full credit, the company’s political spending webpage and/or report must be easily accessible from the home page (within 3 clicks) or through an internet search.

#24 Does the company disclose an internal process for or an affirmative statement on ensuring compliance with its political spending policy?

Altria Group Inc.: “The company conducts regular trainings, compliance system reviews, and internal audits to ensure all PAC and corporate political contributions are made in accordance with the law and company policies.”